In re Criminal Complaint & Application for Arrest Warrant (Concurrence)

CourtSupreme Court of Connecticut
DecidedJuly 1, 2024
DocketSC20995
StatusPublished

This text of In re Criminal Complaint & Application for Arrest Warrant (Concurrence) (In re Criminal Complaint & Application for Arrest Warrant (Concurrence)) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Criminal Complaint & Application for Arrest Warrant (Concurrence), (Colo. 2024).

Opinion

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopin- ion motions and petitions for certification is the “offi- cially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Jour- nal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************ Page 0 CONNECTICUT LAW JOURNAL 0, 0

2 ,0 0 Conn. 0 In re Criminal Complaint & Application for Arrest Warrant

ECKER, J., concurring in the judgment. I would dis- miss on other grounds. The statute at issue, General Statutes § 9-368, provides that, when three electors sub- mit a sworn, written complaint to a judge of the Superior Court, averring that a violation of the election laws has occurred in their town ‘‘and can be proved, such judge shall issue a warrant for the arrest of the accused.’’ Although the duty to issue an arrest warrant appears to be mandatory if the statutory criteria are met, the majority dismisses the present writ of error on the ground that the plaintiffs in error1 lacked ‘‘a judicially cognizable interest in the prosecution or nonprosecu- tion of another.’’ Part II of the majority opinion. The majority’s conclusion is flawed because § 9-368 bestowed on the plaintiffs in error a judicially cognizable interest in the issuance of the requested arrest warrants. The plaintiffs in error were deprived of this statutory inter- est by the trial court’s denial of their applications, and, therefore, they were classically aggrieved for the pur- pose of appellate review. I nevertheless conclude that the present writ of error must be dismissed because it is not the proper procedural vehicle by which to chal- lenge the denial of an arrest warrant application filed in accordance with § 9-368. The plaintiffs in error were parties to the underlying proceeding who were aggrieved by the final judgment of the trial court, and appellate review is available only by means of a direct appeal under General Statutes § 52-263.2 For this rea- The plaintiffs in error are three electors in the city of Bridgeport: Diahann 1

Phillips, Alison Scofield, and Albert Bottone. 2 General Statutes § 52-263 provides that ‘‘[u]pon the trial of all matters of fact in any cause or action in the Superior Court, whether to the court or jury, or before any judge thereof when the jurisdiction of any action or proceeding is vested in him, if either party is aggrieved by the decision of the court or judge upon any question or questions of law arising in the trial, including the denial of a motion to set aside a verdict, he may appeal to the court having jurisdiction from the final judgment of the court or of such judge, or from the decision of the court granting a motion to set aside a verdict, except in small claims cases, which shall not be appealable, and appeals as provided in sections 8-8 and 8-9.’’ 0, 0 CONNECTICUT LAW JOURNAL Page 1

0 Conn. 0 ,0 3 In re Criminal Complaint & Application for Arrest Warrant

son, I would dismiss the present writ of error without prejudice to the filing of a motion for permission to file a late appeal.3 A right of appellate review exists under § 52-263 if the appellant can ‘‘establish in the following sequence that: (1) it was a party to the underlying action; (2) it was aggrieved by the trial [court’s] decision; and (3) the appeal is from a final judgment.’’ State v. Salmon, 250 Conn. 147, 162–63, 735 A.2d 333 (1999). In contrast, appellate review is available by means of a writ of error ‘‘only . . . from a final judgment of the Superior Court to the Appellate Court’’ in cases involving, among other things, ‘‘a decision binding on an aggrieved nonparty . . . .’’ Practice Book § 72-1 (a) (1). One of the ‘‘primary distinction[s] between appeals and writs of error’’ is that ‘‘[a] writ of error is the means by which a nonparty may seek review of a final judgment,’’ whereas ‘‘[a]n appeal is the means by which a party may seek review of a final judgment.’’ Redding Life Care, LLC v. Redd- ing, 331 Conn. 711, 726, 207 A.3d 493 (2019). The two avenues of relief, although similar, are mutually exclu- sive, and a writ of error cannot ‘‘be brought in any civil or criminal proceeding for the correction of any error where . . . the error might have been reviewed by pro- cess of appeal, or by way of certification . . . .’’ Prac- tice Book § 72-1 (b) (1). It is undisputed that this case arose from an ‘‘action’’ in the trial court that culminated in a final judgment. See Board of Education v. Tavares Pediatric Center, 276 Conn. 544, 555, 888 A.2d 65 (2006) (‘‘[T]he word action means the lawful demand of one’s right in a court of justice; and in this sense it may be said to include any proceeding in such a court for the purpose of 3 In light of my conclusion, I need not address whether statutory aggrievement is a jurisdictional prerequisite to the filing of a writ of error. See part I of the majority opinion. Page 2 CONNECTICUT LAW JOURNAL 0, 0

4 ,0 0 Conn. 0 In re Criminal Complaint & Application for Arrest Warrant

obtaining such redress as the law provides. . . . It includes not only the usual civil action instituted by process but also proceedings initiated by petition . . . stipulation . . . or motion.’’ (Citation omitted; empha- sis omitted; internal quotation marks omitted.)); see also In re Naturalization of Fordiani, 98 Conn. 435, 444–45, 120 A. 338 (1923) (petition for naturalization is action from which party who was denied relief may appeal); Waterbury Blank Book Mfg. Co. v. Hurlburt, 73 Conn. 715, 717–18, 49 A. 198 (1901) (arbitration pro- ceeding entered into by stipulation and accepted by trial court was action from which ‘‘[an] appeal to the Superior Court was well taken’’). I therefore focus my analysis on whether the plaintiffs in error (1) were parties to the underlying action, and (2) were aggrieved by the decision of the trial court. ‘‘[T]he word party has a technical legal meaning, referring to those by or against whom a legal suit is brought . . . the party plaintiff or defendant, whether composed of one or more individuals and whether natu- ral or legal persons.’’ (Internal quotation marks omit- ted.) State v. Salmon, supra, 250 Conn. 154. In the present case, the plaintiffs in error initiated a judicial proceeding by filing with a judge of the Superior Court a complaint and arrest warrant application pursuant to § 9-368. See State v. One or More Persons over Whom the Court’s Jurisdiction Has Not Yet Been Invoked, 107 Conn. App. 760, 767, 946 A.2d 896

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